United States v. William Eaton
692 F. App'x 321
| 8th Cir. | 2017Background
- William Eaton pleaded guilty to a federal child‑pornography charge pursuant to a plea agreement that included an appeal waiver.
- The district court accepted the plea and sentenced Eaton within the Guidelines range and imposed ten years of supervised release with conditions.
- Eaton filed a pro se appellate brief challenging district‑court jurisdiction, the constitutionality of the statute, the validity of his guilty plea, and the constitutionality of supervised release.
- Appellate counsel filed an Anders brief and moved to withdraw, suggesting the sentence was substantively unreasonable.
- The government (implicitly) defended the conviction, plea, and sentence and relied on the appeal waiver.
- The Eighth Circuit reviewed the record under Penson and addressed whether any issues were cognizable given procedural defaults and the appeal waiver.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction | District court lacked subject‑matter jurisdiction | Federal district courts have jurisdiction over federal criminal offenses | Rejected; § 3231 supplies jurisdiction (White Horse) |
| Validity of guilty plea | Plea was unknowing/involuntary | No district‑court motion to withdraw plea; plea colloquy showed voluntariness | Not considered on appeal due to failure to move to withdraw in district court (Foy) |
| Constitutional challenge to statute | Statute of conviction unconstitutional | Issue waived by failure to raise in district court | Not considered; waived for failure to raise below (Baker) |
| Sentence reasonableness / appeal waiver | Sentence substantively unreasonable; other procedural challenges | Appeal waiver was knowing and voluntary; counsel’s Anders brief raises no nonfrivolous issues outside waiver | Appeal waiver enforced; no nonfrivolous issues outside waiver; judgment affirmed; counsel allowed to withdraw (Andis; Scott; Penson) |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (1967) (procedures for counsel seeking to withdraw on appeal when brief finds no meritorious issues)
- Penson v. Ohio, 488 U.S. 75 (1988) (court must independently review the record when counsel seeks to withdraw)
- United States v. White Horse, 316 F.3d 769 (8th Cir. 2003) (§ 3231 supplies subject‑matter jurisdiction in federal criminal prosecutions)
- United States v. Foy, 617 F.3d 1029 (8th Cir. 2010) (failure to move to withdraw guilty plea in district court forfeits claim on direct appeal)
- United States v. Baker, 98 F.3d 330 (8th Cir. 1996) (failure to raise constitutional challenge in district court waives the issue on appeal)
- United States v. Amerson‑Bey, 898 F.2d 681 (8th Cir. 1990) (declining to address unraised constitutional objections to sentence)
- United States v. Scott, 627 F.3d 702 (8th Cir. 2010) (de novo review of validity and applicability of appeal waiver)
- United States v. Andis, 333 F.3d 886 (8th Cir. 2003) (en banc) (standards for enforcing appeal waivers and importance of plea colloquy)